Road Haulage 2025–2026: Waiting Times at Loading/Unloading, Payment Terms and Incentives for Fleet Renewal

What has changed (and what to do now) for companies and supply chains

Introduction

In 2025, the road haulage framework was updated through measures with direct operational impact on principals/clients, shippers, operators of logistics platforms and carriers, including:

mandatory rules on waiting times at loading/unloading, with a 90-minute grace period and hourly compensation beyond that threshold;
payment terms for freight charges remaining capped at 60 days, with strengthened protection against systematic delays;
Ministerial incentives for fleet renewal (alternative propulsion purchases, scrappage schemes, intermodal transport).

The scope derives from Decree-Law No. 73 of 21 May 2025 (the so-called “Infrastrutture” Decree), converted into Law No. 105 of 18 July 2025, from MIT clarifying circulars (waiting times and payments), and from MIT decrees governing investment support measures. For businesses, this translates into new obligations regarding traceability and evidence (times, DDT/CMR, gate systems), the alignment of contractual clauses throughout the supply chain, and investment planning to access available incentive windows.

Who it applies to: principals/clients and shippers (including hubs and third-party warehouses), 3PL/4PL operators, carriers and sub-carriers.
Why now: enforcement activity (MIT/AGCM) is ongoing and incentives are awarded on a “first-come, first-served” basis; contracts, procedures and recording systems should be aligned to avoid disputes and secure contributions.

At a glance

Waiting times: 90-minute grace period; compensation payable thereafter, with detailed traceability requirements.
Payments: 60 days from invoice date; AGCM sanctions may apply in case of widespread dilatory practices.
Incentives: dedicated lines for alternative-fuel/Euro VI vehicles, scrappage and intermodal transport; close attention required as to eligibility and deadlines.

1) Waiting times at loading/unloading: 90-minute grace period and automatic compensation

Strict grace period: 90 minutes for each loading and each unloading operation, calculated from the time the vehicle arrives at the indicated location.
Compensation: EUR 100 per hour (or part thereof) beyond the grace period, payable to the carrier.
Mandatory rule, clarified by the MIT in Circular No. 13485 of 4 November 2025.

Operationally: to evidence waiting time, record arrival/start-of-operations times via CMR/DDT, arrival logs, or gate/access control systems; stoppages attributable to the principal/shipper are included in the calculation.

2) Payment terms: 60 days confirmed, strengthened protection

The maximum payment term for transport consideration remains 60 days from the invoice date (Legislative Decree 231/2002 and Art. 83-bis(12), Decree-Law 112/2008).
Decree-Law 73/2025 introduced Art. 83-bis(15-bis): where widespread and repeated delays occur, the AGCM may act ex officio or following a report (including by the Central Committee of the Register/Albo), applying the sanctions under Art. 15 of Law 287/1990 (up to 10% of turnover).

Source: MIT Circular – Central Committee of the Albo, No. 4505 of 19 November 2025.

3) Incentives for fleet renewal (MIT)

Under Ministerial Decree No. 203 of 7 August 2025 (Official Gazette No. 244/2025) and MIT Director’s Decree No. 470 of 4 December 2025 (Official Gazette No. 289/2025), resources and procedures were set for grants supporting:
a) purchase of alternative-propulsion/electric vehicles;
b) scrappage + purchase of Euro VI step E vehicles;
c) trailers/semitrailers for rail/sea intermodal transport and ATP equipment.
With MIT Ministerial Decree of 2 January 2026 (Official Gazette No. 15/2026), the maximum contribution cap was increased to EUR 700,000 per undertaking per each incentive period.

Measures are funded under budget line 7309; annual calls with click day and dedicated windows: monitor MIT notices.

4) Operational Q&A

When do the 90 minutes start? From the vehicle’s arrival at the loading/unloading location (not from the “slot” time). Traceability is essential.
What if the delay is attributable to the carrier? Compensation is not due; the MIT circular refers to strictly construed exonerating causes.
Can the 60-day term be extended? No: it is a maximum cap; the new rules enable AGCM action against widespread/repeated dilatory practices.
Will incentives continue in 2026? The framework is updated annually through MIT acts; check the latest notices and click-day announcements.

How we can assist (Studio Legale Rosano approach)

Supply-chain contract audit (principal–shipper–carrier–warehouses) and alignment of clauses on waiting time/compensation and payment terms.
Evidentiary/traceability procedures for waiting time (gate policy, digital evidence, DDT/CMR).
AGCM risk management in relation to repeated payment delays: prevention, reporting, defence.
Incentive plans: eligibility checks, timelines and documentary support for MIT calls.

For a rapid review of your logistics contracts or to assess eligibility for the 2026 incentives, contact us: we will align documents and processes in due time with respect to the call schedule and seasonal peaks.

Key legal references

Decree-Law No. 73 of 21 May 2025 – “Infrastrutture” (Official Gazette No. 116/2025), Law No. 105 of 18 July 2025 (Official Gazette No. 166/2025), consolidated text.
MIT Circular – Albo Committee No. 13485 of 4/11/2025 (waiting times) and No. 4505 of 19/11/2025 (payments).
MIT Ministerial Decree No. 203 of 7 August 2025 (Official Gazette No. 244/2025) and MIT Director’s Decree No. 470 of 4 December 2025 (Official Gazette No. 289/2025) – fleet renewal incentives.
Assolombarda summary factsheet.
MIT Ministerial Decree of 2 January 2026 (Official Gazette No. 15 of 20/01/2026) – amendment of incentive caps.

Note: content aligned as of 22 January 2026 (Europe/Rome). For subsequent windows, verify the most recent MIT notices.

How we can assist

Supply-chain contract audit (principal–shipper–carrier–warehouses) and alignment of clauses on waiting time/compensation and payment terms.
Evidentiary/traceability procedures for waiting time (gate policy, digital evidence, DDT/CMR).
AGCM risk management in relation to repeated payment delays: prevention, reporting, defence.
Incentive plans: eligibility checks, timelines and documentary support for MIT calls.

22/01/2026